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Why the Animal Testing Licensing System Is Not Working

The tragic situation for the animals at Imperial College also shows the need for more transparency, with publication of full project licences (with names and confidential information removed) instead of sanitised PR summaries.

When animal experiments are discussed, the Government and animal research industry are quick to make statements such as:

'The UK has one of the most rigorous systems in the world to ensure that animal research and testing is strictly regulated' (Home Office Minister, Lynne Featherstone, July 14 2011)

'These controls are widely regarded as the strictest in the world.' 'Pain and distress must be minimised and the UK controls state that there must be a vet on call at all times. These controls also make sure that any animal suffering severe pain which cannot be alleviated is put down immediately.' (Understanding Animal Research)

Such strong statements are made to reassure the public that animals are only used when no alternative exists, that they are well looked after, suffering is kept to a minimum and they are humanely killed at the end of the experiment. Animal research, however, is surrounded by such secrecy that it is impossible for the public to judge for themselves. The revelations at Imperial College London, ranked as one of the best universities in the world, as uncovered by a recent BUAV investigation, show again not only how the system is spectacularly failing, but also provides another chilling insight into the attitude and behaviour of researchers and staff whose job it is to look after the animals in their care.

A BUAV investigator worked for seven months at Imperial College, and documented a catalogue of shortcomings and wrongdoing by staff and researchers that caused substantial distress and suffering to the animals in its care, even more than was already allowed in the experiments. Findings included: breaches in and lack of knowledge of UK Home Office project licences; a failure to provide adequate anaesthesia and pain relief; incompetence and neglect and highly disturbing methods used to kill animals.

Much of the evidence accumulated by the BUAV investigator includes statements by the researchers and staff themselves; their own admissions of wrongdoing, neglect and incompetence resulting in unnecessary and illegal animal suffering. Statements such as 'If the Home Office was in we would have been screwed' after mice were found in a pitiful distressed state on a Monday morning because of a failure to adequately monitor them over the weekend. Or a researcher who laughingly admitted about his project licence: 'The license is pretty generous actually. We've written it so that it's quite good at, we can do all sorts.' Or another researcher who gave a rat a reduced dose of anaesthesia because it was late on a Friday afternoon: 'But I won't give it a full dose. As long as there is enough for it to be not fully under but you know not feeling too much pain.' These are all disturbing incidents that the public has a right to know took place in one of the UK's leading universities.

Our undercover film makes uncomfortable viewing. After watching the film, the RSPCA released this statement: 'This footage is appalling - one of the worst and most upsetting cases our research animal experts have ever seen. Many of us have been close to tears watching it. It shows total incompetence and a complete disregard for the animals experimented on and the legislation which has been put in place to control animal use.'

According to the Government and research industry, what is supposed to happen as far as the licensing and carrying out of an animal experiment?

1. A researcher seeking approval from the Home Office for an experiment describes what will be done to the animals, how much they are likely to suffer (in categories of mild, moderate, and substantial) and explains why he or she believes the experiment is worthwhile nonetheless.

2. The Home Office weighs up the arguments and only approves the project if it considers that the likely benefits of the experiment outweigh the suffering inflicted on the animals. In particular, if research has already been done using human beings, it is not normally thought to provide additional benefits to repeat it on animals.

3. The research team carries out the experiment, being careful to limit the suffering to what was described in the licence and avoiding unnecessary suffering. The Named Animal Care and Welfare Officers (NACWO) and Named Veterinary Surgeons (NVS) carry out their duties under the legislation.

4. The Home Office inspects the facility to check all is proceeding in accordance with the licence.

5. Animals are monitored sufficiently to ensure that they are not left to suffer unnecessarily. Any animal found to have reached the endpoint allowed in the experiment will be humanely killed. At the end of experiments, the animals will be humanely killed.

6. The public is informed by a project summary, posted on the Home Office website, about what is being done.

But what actually happened in Imperial College?

1. The experiments often involved major surgery with substantial adverse side effects. For example, the removal of both kidneys (replaced by only one). The anticipated side-effects included hunching (indicative of severe pain), diarrhoea, sunken eyes, laboured breathing and 20% body weight loss. The Home Office, absurdly, described these effects as only 'moderate'. Part of the problem is that it bases its assessment on pure fiction - that staff are on hand 24 hours a day, just like in a hospital, to intervene promptly should an animal show particular signs of suffering. There was no overnight cover at Imperial, and precious little at weekends, with predictable consequences - animals found dead in the morning after suffering grievously.

2. The experiments were approved, even though in some cases essentially similar research had already been done or was continuing to be done using human beings, often by the same researchers and with the same results, or could we believe have been carried out using test tube methods.

3. A number of staff conducting various experiments admitted ignorance of the severity limits of the licence and endpoints (at which point an experiment must be stopped to prevent further suffering), without which knowledge it is clearly impossible to adhere to them. In reality, the investigation showed animals in serious distress, suffering greatly. Staff admissions showed that animals were left to live beyond these endpoints, resulting in not only breaches of the project licences, but also unnecessary suffering. Animals were forced to endure all kinds of adverse effects, with sometimes inadequate anaesthesia - imagine being conscious during an operation - and pain relief.

4. Methods used to kill animals 'humanely' as required by the law and the University's own rules were often carried out inadequately and even casually, such as breaking an animal's neck using the edge of a metal cage label holder or by hand. A live, struggling and apparently fully conscious rat was decapitated in the film in a macabre scene with music blaring in the background.

5. The veterinarian was not able to visit two animal areas if he had been in another area within the past 48 hours. The result was that he could not physically examine animals in those areas. An example involved a rat who had become paralysed. No veterinary surgeon is able to do their job properly if they cannot examine an animal.

6. The Home Office inspections apparently failed to detect many of the problems (though they were critical following one inspection). Staff reported that the inspectors did not even open the cages to examine the animals (nor did the staff much of the time).

7. In one example, the public project summary extols the alleged benefit of the research but says very little about what is done to the animals and nothing at all about the adverse effects they are likely to suffer. The project licence itself, by contrast, lists numerous serious adverse effects, including 30% weight loss within 48 hours and a 15% mortality rate from the surgery (the licence would normally have remained secret). As well as invasive surgery, the animals could experience up to 30 injections of various foreign substances, 10 oral gavages (force-feeding of substances down the throat), repeated general anaesthesia for imaging and starvation for 48 hours. The public was not told any of this.

Neither the Home Office nor Imperial College has denied the reports. The College has set up what it describes as an "independent" inquiry by a prominent animal researcher who has a senior position in the Medical Research Council (MRC). The MRC provides funding for Imperial College animal research and so cannot conduct an independent inquiry.

Only last year, Imperial College was one of a number of organisations, including other universities, drug companies and charities, which signed a declaration to be more open about animal research. This move was in response to a government commissioned opinion poll that shows public support for animal experiments has dropped by 10% since 2010.

The BUAV is calling for a genuinely independent inquiry to investigate the ways that the system breaks down and the serious issues that were revealed at Imperial College. If politicians and the animal research community want to be seen as serious about transparency and a rigorous system, is that too much to ask?

The tragic situation for the animals at Imperial College also shows the need for more transparency, with publication of full project licences (with names and confidential information removed) instead of sanitised PR summaries. At present the Government is not allowed to disclose details of a project licence without the permission of the researcher (which in practice is nearly always refused). The Government is reviewing Section 24 of the Animal Scientific Procedures Act that imposes this restriction. Will they finally lift the veil of secrecy?

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